In Support of Application for Asylum (Form I-589)
I, María Dalia Dávila Moreno, declare under penalty of perjury under the laws
of the United States that the following is true and correct to the best of my knowledge:
I. PERSONAL BACKGROUND
My name is María Dalia Dávila Moreno. I was born on January 28, 1981, in Venezuela. I am a Venezuelan citizen. I am the mother of two sons: Alan David Coronado Dávila, born on November 16, 2002, who is an adult and files his own separate asylum application, and Kevin David Coronado Dávila, born on July 30, 2009, who is a minor and is included as a derivative beneficiary in the asylum application of his father, Brigzen Aroldo Coronado Lobo, who also files his own separate application. I am the former spouse of Brigzen Aroldo Coronado Lobo. We are divorced.
I arrived in the United States on October 4, 2018, through John F. Kennedy International Airport in New York, on a B-2 visitor visa. I arrived with my two sons. My former spouse had already been living in the United States since February 2017. I have remained in the United States continuously since the date of my arrival. I have not returned to Venezuela. As of the date of this application, I have lived in the United States for more than seven years.
I currently live in Bozeman, Montana, where I relocated with my family in late 2024. My sons, my former spouse, and other members of my family are here. I have no meaningful support network remaining in Venezuela. My life, my family, and everything I have built during the past seven years are in the United States.
II. MY LIFE IN THE UNITED STATES AND THE LOSS OF TEMPORARY PROTECTED STATUS
After arriving in the United States in October 2018, I applied for and received Temporary Protected Status (TPS) for Venezuela. My TPS was first granted with an effective date of August 15, 2022, and was subsequently renewed, covering me through September 10, 2025. During this period, I was authorized to live and work lawfully in the United States. My sons and my former spouse also held TPS during this period.
On November 7, 2025, the Department of Homeland Security terminated the 2021 Venezuela TPS designation. My TPS, along with that of my sons and former spouse, terminated on that date. I no longer hold TPS or any other lawful immigration status. The termination of TPS was a turning point for me. For the first time since arriving in the United States, the possibility of being forced to return to Venezuela became real and immediate. That possibility frightens me deeply.
I want to explain honestly why I did not seek asylum earlier. During the years I held TPS, I had a lawful basis to remain in the United States and I focused on building stability for myself and my children. I did not fully understand the difference between TPS and asylum, and the prospect of forced return did not feel immediate while TPS was in place. When TPS was terminated, my former spouse — who has always taken the lead in researching and navigating legal and administrative processes for our family — began exploring asylum as a path forward. We sought legal advice from an attorney in December 2025, but after several months concluded that the approach being proposed did not honestly reflect our circumstances. After ending that relationship in April 2026, we reorganized and prepared our applications based on what is true. I am filing within a reasonable period following the termination of my TPS, which constitutes the changed circumstance that made my need for asylum protection urgent and concrete.
III. MY POLITICAL VIEWS AND MY EXPOSURE ON SOCIAL MEDIA
I am opposed to the government of Nicolás Maduro and to the Chavista political movement that has governed Venezuela for more than two decades. I did not support that government when I lived in Venezuela, and I do not support it now. This is a genuine political position that reflects my understanding of what the Venezuelan government has done to the country and to its people.
Since living in the United States, I have followed events in Venezuela closely, particularly through social media. I maintain accounts on Facebook, Instagram, and TikTok under my real name. In January 2026, when events surrounding the capture of Nicolás Maduro became public, I interacted with content on those platforms related to those events. My accounts are public and are registered under my full name. I am identifiable on those platforms as a Venezuelan national living in the United States.
I am aware that the Venezuelan government enacted legislation in November 2024 — the Ley Orgánica Libertador Simón Bolívar contra el Bloqueo Imperialista y en Defensa de la República Bolivariana de Venezuela, published in Official Gazette No. 6,859 Extraordinary — that expressly sanctions the dissemination through electronic media and social networks of content that the government characterizes as promoting measures against Venezuela or its sovereignty. The language of that law is broad. It does not require that a person have published original content calling for sanctions or foreign intervention. It encompasses any expression in digital spaces that the government interprets as favorable to foreign interests or hostile to its authority. For a person like me — a Venezuelan woman who has lived in the United States for more than seven years under American immigration protection, whose name and identity are visible on public social media accounts, and who has interacted with content related to events the Venezuelan government has characterized as a foreign attack against its territory — that legal framework creates a real and concrete risk.
IV. MY FAMILY PROFILE AND THE RISK IT CREATES
My fear is also grounded in the profile of my family as a whole, which I believe the Venezuelan government would view with suspicion and hostility.
My former spouse, Brigzen Aroldo Coronado Lobo, was known within his personal and community circle in Venezuela as a person who openly opposed the Chavista government. He has lived in the United States since February 2017 — more than nine years — and held TPS for several years. My son Alan has lived in the United States since he was fifteen years old and has built his entire adult life here. My son Kevin has lived here since 2018 and has been educated entirely in the United States.
Additionally, Brigzen’s brother, Rodney Coronado Lobo, had a publicly visible association with government-aligned political organizations in Venezuela. He now lives in the United States as a lawful permanent resident, married to a United States citizen, with daughters who are also United States citizens. The combination of these facts — a family that includes a person with a past public association with the Chavista movement who now lives in the United States with an American family, a former spouse who openly opposed the government and has lived here for nine years, and children who have been formed entirely in the United States — creates a family profile that the Venezuelan government would likely view as politically unreliable, disloyal, or connected to foreign interests.
As the mother of these children and the former spouse of Brigzen Coronado Lobo, I am part of that family. I share that profile. If I were to return to Venezuela, I would not be returning as an anonymous individual. I would be returning as a member of a family that the government has reason to scrutinize, and as a woman whose name and identity are publicly visible on social media platforms where she has interacted with content related to events the government has labeled a foreign attack against Venezuela.
V. THE LEGAL AND POLITICAL FRAMEWORK THAT SHAPES MY FEAR
My fear is not based on speculation about what might happen in Venezuela. It is grounded in what the Venezuelan government has formally established as the legal basis for investigating, registering, and prosecuting individuals it perceives as connected to foreign interests or opposed to its authority.
The Ley Orgánica Libertador Simón Bolívar, enacted in November 2024, criminalizes with prison sentences of twenty-five to thirty years any conduct the government characterizes as promoting, supporting, or facilitating international sanctions or actions against Venezuela’s sovereignty. The law’s language is deliberately expansive. It reaches not only direct action but perceived sympathy, indirect support, or conduct interpreted as favorable to foreign interests — including content shared or engaged with on social media platforms. The law also creates a National Registry of suspected individuals, with immediate administrative consequences.
On January 3, 2026, the Venezuelan government published Decree No. 5,200 in Official Gazette No. 6,954 Extraordinary, declaring a State of External Commotion across the entire national territory. The decree was issued in the context of the capture of Nicolás Maduro on that date, which the government characterized as an armed attack by the United States. Article 5 ordered the immediate search and capture of any person involved in the promotion or support of that alleged attack. The scope of that language — promotion and support, not only direct participation — is precisely what makes it threatening to someone like me.
What I have observed since these events is not abstract. Reports have emerged of Venezuelan nationals being detained or disappeared upon arriving at Venezuelan airports — people who had been living abroad and chose or were forced to return. Senior Venezuelan government officials have made public statements specifically referencing Venezuelans who held TPS in the United States, characterizing them in terms that suggest suspicion and hostility rather than welcome. I have followed these developments closely and they have deepened my fear. The message I have received from what I have seen and heard is that returning Venezuelans who lived under American immigration protection are not viewed by this government as ordinary citizens coming home. They are viewed as people who need to be questioned, monitored, and potentially held accountable for having lived under the protection of a government that Venezuela’s leaders have declared an enemy.
VI. WHY I CANNOT SEEK PROTECTION IN VENEZUELA
I cannot seek protection from Venezuelan authorities because the Venezuelan government is the source of the threat I fear. Venezuela has no functioning independent judiciary. There is no institution within Venezuela capable of protecting a person from persecution by the state itself. The legal frameworks that exist — including the Ley Simón Bolívar and the state of exception declared in January 2026 — have expanded the government’s authority to act against individuals it perceives as threats, while eliminating or weakening the legal safeguards that might otherwise constrain that authority.
Relocating within Venezuela would not protect me. The Venezuelan government’s security apparatus — including the SEBIN (Servicio Bolivariano de Inteligencia Nacional, or Bolivarian National Intelligence Service), which functions as the government’s political police and has been associated with arbitrary detention and the suppression of dissent, and the DGCIM (Dirección General de Contrainteligencia Militar, or General Directorate of Military Counterintelligence), the military intelligence body responsible for internal surveillance and political repression — operates throughout the entire national territory. The colectivos, armed pro-government groups that enforce political loyalty through intimidation and violence at the community level, are present in communities across Venezuela. There is no location within the country where I could live without the risk that my profile — my years in the United States, my public social media presence, my family connections — would reach me.
I also want to note a practical reality: Venezuela does not maintain an operational embassy in the United States. My Venezuelan passport is expired, and I have no means of renewing it from within this country. This is not a choice I have made. It is a consequence of the Venezuelan government’s failure to maintain consular services here — a failure that itself reflects the broken relationship between that government and the millions of its citizens who have been forced to live abroad.
VII. CONCLUSION
I am asking the United States government for protection from being returned to Venezuela. I am a forty-five-year-old woman who has lived in this country for more than seven years, raised my children here, and built the only stable life I have known in a long time. I have no meaningful life to return to in Venezuela — not because I chose to abandon it, but because the conditions that government has created made it impossible to remain.
My fear is genuine. It is based on who I am, on the family I belong to, on the public visibility of my identity on social media, on the formal legal mechanisms the Venezuelan government has created to persecute people with my profile, and on what I have observed happening to Venezuelans who return from the United States. I am not exaggerating my circumstances. I am describing them honestly, and I am asking for the protection that this application seeks.
I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct to the best of my knowledge and belief.
Executed on: ___________________________
_______________________________________
María Dalia Dávila Moreno
Date of Birth: January 28, 1981
Bozeman, Montana